Written Evidence Submitted by the Safer Disinfectants Network
(CLL0086)
Summary
The Safer Disinfectants Network (SDN) welcomes the opportunity to make this submission of written evidence to the Health and Social Care and Science and Technology Select Committees’ joint inquiry into lessons learnt from coronavirus.
This inquiry comes at an important juncture. It is vital the UK learns lessons from management of the pandemic to-date if we are to manage the virus during the coming months; enable greater social interactions in 2021; and ensure the UK is prepared for future public health threats and is able mitigate risk and threat to life.
As part of these lessons and preparation for the future, it is essential the committees and the government consider the importance of infection control – specifically the use of disinfectant products, not only within NHS and social care settings, but in workplaces across the country and by members of the public in their own homes.
Just as social distancing measures helped supress the reproduction rate during lockdown, so robust infection control and hygiene protocols and guidance ensure the risk of transmission at home and in the workplace is reduced. This must extend beyond guidance on how to sanitise and include what end users should look for in the disinfectant products they are purchasing.
The consequences of using disinfectant products that do not provide adequate levels of protection from pathogens including viruses is that there is an increased risk to the public of transmission, including of coronavirus. Some disinfectant products can also have a corrosive effect on materials exposed to them, which in the case of NHS settings risks damage to essential and high value equipment.
There are currently minimal requirements on disinfectant products in the UK to be able to substantiate claims made about their efficacy on packaging or in marketing materials. This is deeply concerning, particularly at a time when demand for such products has increased as a consequence of the pandemic – creating the risk that consumers (whether the public, businesses or public sector) purchase lower cost products that have not been subject to rigorous testing and do not provide appropriate levels of protection.
Alongside lessons with regards to suppressing coronavirus through measures such as social distancing, it is essential the UK improves its approach to infection control and has rigorous standards in place to ensure the effectiveness of disinfectant products on the market.
About the Safer Disinfectant Network
The SDN is a collaboration of leading infection control companies, committed to promoting best practice and ensuring public safety by encouraging high standards of effectiveness within disinfectant products, based on rigorous testing and independent clinical evidence, and clarity on claims of product efficacy.
Members of the SDN include Gama Healthcare, Ecolab, Clorox, Diversey and PDI Healthcare.
Written evidence
Infection control has arguably been understated amongst the non-pharmaceutical measures to manage the pandemic.
Whilst the government has provided helpful guidance in terms of workplace practices and hygiene protocols aimed at reducing transmission rates, there is an opportunity to go further to embed best practice. This includes providing further guidance on the types of disinfectant products end users should be utilising and how they should be used.
There is a risk that without this information, government guidance – though well-intentioned – may be ineffective, or at least less effective, in reducing the risk of contamination and transmission. This is within a context in which the number of disinfectant products on the market has increased significantly to meet enhanced consumer demand. However, there remains little in the way of regulation on the development, packaging and marketing of products. This means it is possible for disinfectants to make unsubstantiated or misleading claims about their efficacy against pathogens and viruses, including coronavirus.
Consequently, particularly if the purchasing of disinfectant products is solely cost-driven, there is a risk of products not providing adequate levels of protection. Thus, there is a strong case for introducing requirements on manufacturers to be able to demonstrate the efficacy of their products and substantiate any claims on the packaging and marketing through testing and independent clinical research.
The other essential component is guidance on correct usage of disinfectant products. This is particularly important at a time when public services, including the NHS, are experiencing high levels of demand. Robust protocols must be in place to maximise the effectiveness of disinfecting and sanitising equipment and surfaces to reduce transmission risk.
A final issue for consideration in terms of the procurement of disinfectant products, particularly by the NHS, is compatibility with equipment and devices. Products with a high alkaline content can cause corrosion and damage, taking high value equipment out of service and incurring significant cost for repair and replacement. Settings must have guidance on appropriate disinfectant products and their usage to avoid such damage, which would erode any short-term savings if procurement is largely or wholly driven by cost.
Further guidance can and should be provided to social care settings as to appropriate disinfectant products for their sanitising and cleaning regimens, and how these products should be used most effectively.
With government data showing residential social care settings to harbour particularly high risks of infection and transmission, embedding best practice can reduce risk levels and best protect residents. This is also true in instances where members of the public have in-home care.
As outlined above, with the expansion of the disinfectant market, and in the absence of strong regulation and legal requirements, there is a risk of products making inaccurate and unsubstantiated claims about their efficacy or lacking robust testing and independent research to prove their effectiveness. This has the potential to lead to social care settings using products that provide inadequate protection for residents against pathogens and viruses, including coronavirus – especially if cost is a driving factor in procurement.
Given the paramount importance of infection control in suppressing this and potential future pandemics, it would be sensible for the government to consider how standards could be imposed on disinfectant products and enforced if required.
Government communications on basic hygiene and social distancing have been important in suppressing the spread of coronavirus, as has specific guidance for different workplaces.
Going forward this could be enhanced by two measures: readily available guidance on what consumers should look for in the disinfectant products they are purchasing and how to use them effectively; and regulation of products to prevent against misleading or inaccurate efficacy claims.
At present, minimum standards and a lack of regulation mean it is possible for products to claim inaccurate levels of efficacy – i.e. the disinfectant product you purchase may not be effective against coronavirus or ’99 percent of bacteria,’ as some claim. This risks lulling members of the public, but also businesses and public sector workers, into a false sense of security regarding their protection. Wiping a surface or spraying/wiping equipment with an ineffective product may fail to achieve the desired objective.
Expanding on existing guidance and taking steps to prevent false or inaccurate efficacy claims on packing and marketing materials would better serve and protect the public as we continue to manage the crisis; and serve as value preparation for future public health issues.
The UK appears to have learned many lessons from this pandemic, including the impact of social distancing measures and the role of testing and tracing.
Further action is required to protect the public in terms of effective infection control – specifically by preventing products from making inaccurate or misleading claims as to their efficacy; ensuring any claims can be substantiated through rigorous testing and independent research; and expanding on public guidance on how to use products more effectively at home and in the workplace.
This would help reduce risk of transmission, thereby contributing to suppression efforts and efforts to manage NHS resources.